News & Analysis as of

Virtual Currency Suspicious Activity Reports (SARs) Bank Secrecy Act

Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender... more +
Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency.    less -
Perkins Coie

FinCEN Addresses Increased Fraud Involving Convertible Virtual Currency Kiosks

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Key Takeaways - - The Financial Crimes Enforcement Network’s recently issued notice, which addresses regulations and increased rates of fraud surrounding convertible virtual currency kiosks, carries significant implications...more

Ballard Spahr LLP

“Pig Butchering”: FinCEN Issues Alert on Virtual Currency Scam

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On September 8, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released an alert regarding a notorious virtual currency scam called “pig butchering,” because, unfortunately, it resembles the “fattening a hog before...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

Ballard Spahr LLP

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

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The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

Freeman Law

FinCEN Provides Reminder About BSA Reporting Requirements

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FinCEN and Bank Secrecy Act Reporting - On March 7, 2022, the Financial Crime Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury alerted financial institutions “to be vigilant against efforts to...more

Harris Beach Murtha PLLC

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

Alston & Bird

Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021

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On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more

Ballard Spahr LLP

FinCEN and CFTC Reach Groundbreaking $100 Million AML Settlement with BitMEX

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Government Alleges Systemic and Deliberate AML Failures - Filings Describe Tools for CVC Exchanges to Use for Customer Due Diligence and Transaction Monitoring - The Financial Crimes Enforcement Network (“FinCEN”) and...more

Orrick, Herrington & Sutcliffe LLP

Off‐Shore Crypto Exchange to Pay Up to $100 Million to Resolve Enforcement Action with U.S. Regulators

The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more

King & Spalding

FinCEN Proposes Lower Travel Rule Thresholds for Fiat and Virtual Currencies

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In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more

Ballard Spahr LLP

To Fight Terrorism, FinCEN and Federal Reserve Board Request Comment on Proposed Major Expansion of Recordkeeping and Travel Rules...

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Proposed Change Would Expand BSA Definition of “Money” to Include Virtual Currency - The Financial Crimes Enforcement Network (“FinCEN”) and the Federal Reserve Board (“Board”) have requested comment on an important...more

Orrick - On the Chain

In Case You Needed A Reminder – AML/CFT Regulations Apply to Transactions in Cryptocurrencies

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Earlier this month, the leaders of the U.S. Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, and the U.S. Securities and Exchange Commission released a joint statement reminding individuals...more

Perkins Coie

Blockchain Week in Review - October 2019

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U.S. Developments - U.S. Federal Regulatory Developments - CFTC, FinCEN, and SEC Leaders Release a Join Statement on Digital Assets - On October 11, 2019, the heads of the Commodity Futures Trading Commission (“CFTC”),...more

Blank Rome LLP

FinCEN Director Emphasizes AML Priorities for Casinos, Sports Wagering, Mobile Gaming, and Card Clubs in Las Vegas Speech

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As underscored in a recent speech by the director of the Financial Crimes Enforcement Network (“FinCEN”), compliance officers should ensure that their anti-money laundering (“AML”) programs are current with FinCEN’s...more

Foodman CPAs & Advisors

If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)

FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more

Jones Day

Financial Crimes Enforcement Network Consolidates Guidance on Virtual Currencies

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The Situation: The Financial Crimes Enforcement Network ("FinCEN") released interpretive guidance concerning the application of the Bank Secrecy Act ("BSA") and the anti-money laundering ("AML") regulations to certain...more

Robinson+Cole Data Privacy + Security Insider

New FinCEN Cryptocurrency Guidance Clarifies Applicability of Anti-Money Laundering Regulations to Virtual Currency Business...

The Financial Crimes Enforcement Network (FinCEN) is the U.S. Treasury Department bureau charged with monitoring financial transactions in order to combat domestic and international money laundering, terrorist financing and...more

Eversheds Sutherland (US) LLP

Application of FinCEN’s regulations to certain business models involving convertible virtual currencies

On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) issued interpretive guidance1 summarizing the application of the Bank Secrecy Act (BSA) rules to business models “involving money transmission denominated in...more

Ballard Spahr LLP

FinCEN Director Addresses Virtual Currency and Touts Regulatory Leadership and Value of SAR Filings

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Address Emphasizes Role of SARs in Fighting Illegal Activity, Including Drug Dealing Fueling the Opioid Crisis - Kenneth Blanco, the Director of the Financial Crimes Enforcement Network (“FinCEN”), discussed last week...more

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